Contact

The contact for this document will be the National Manager, Grains and Oilseeds Section, Plant Health and Biosecurity Directorate (PHBD), CFIA.

Review

This directive will be updated as required. For further information or clarification, please contact the Canadian Food Inspection Agency (CFIA).

Endorsement

This PI-001 is hereby approved:

Gregg Wolff, Chief Plant Health Officer

Date

0.0 Introduction

Certain Canadian facilities directly export grains and field crops. Grains and field crops for export may have to be certified free from regulated stored product pests, as per the requirements of plant health authorities in the importing countries. The CFIA issues this certification by way of a Phytosanitary Certificate based on inspections of facilities, stored products, and transportation vehicles. The CFIA will certify products exported from facilities which meet the requirements of the CFIA. This PI-001 specifies the procedures that inspectors must follow to inspect facilities and their stored products.

1.0 Scope

This PI-001 specifies the procedures that inspectors must follow to inspect facilities that export grains and field crops, including transfer and terminal elevators. These procedures do not encompass facilities that handle both grains and field crops and non-food (or feed) products (e.g., fertilizers). This PI-001 does not specify the general roles and responsibilities of inspectors. These roles and responsibilities shall be outlined in documents such as memoranda of understanding, internal work plans, or other agreements.

Agriculture and Agri-Food Canada (AAFC) and the CGC, 1994. Memorandum of Understanding between the CGC and the Department of Agriculture (Food Production and Inspection Branch) Concerning the Sampling and Inspection of Grain and Grain Handling Facilities to Meet Phytosanitary Export Market Requirements. AAFC, Ottawa,

Separate reports for large facilities can be initiated only where multiple workhouses exist and there is an effective means to isolate an individual workhouse, if necessary. A workhouse is an area for receiving and processing grain. It is constructed of several floors on which may be located scales, cleaning machinery, holding bins, bucket elevators (legs), spouting and miscellaneous grain handling equipment. This can only be implemented with prior approval of the management of the facility and the National Manager of the Grains and Field Crops Section, PHD.

4.1 Summary of Procedures

Where CGC inspectors are inspecting on behalf of the CFIA, they should immediately notify the CFIA when pests of quarantine significance to Canada have been found. The CFIA inspectors will conduct concurrent inspection with CGC inspection staff as per Section 4.8. See Section 4.4.3 for a description of conformance levels.

Plan the inspection.

Begin the inspection and bring along the last report if corrective actions require follow-up.

Complete the inspection noting any sanitation and insect infestation problems that should be brought to the immediate attention of the facility management.

Identify of confirm identification of any inspections found and analyze data collected during the inspection.

Calculate points lost for sanitation and infestation, calculate conformance level and determine corrective actions to be taken.

Report results and do follow-up actions as required based on conformance level

Write and distribute the inspection report and warning letter, conduct follow-up inspections within 10 days or soon after corrective actions are done (C, F).

4.2 Planning Inspections

Inspectors shall:

Review previous inspection reports on the facility to be inspected.

Determine if the facility is due for inspection. A facility must be inspected as specified in Section 4.2.1 or 4.2.2 as applicable. The number of inspections that have been conducted during a year for a facility can be determined by reading the number of the most recent inspection report for the facility. Section 4.6.2 outlines how to read inspection report numbers.

Determine which areas of the facility were previously infested with primary or secondary insects and ensure that the inspection plan includes a thorough review of these areas. An area may be a floor or identifiable location within the facility, for the purpose of establishing sanitation/infestation ratings in which a specific function is conducted, or which is exposed to similar sanitation and/or infestation risks. A primary and secondary insect pests feed on grains and/or field crops; primary pests can establish in storage whereas secondary pests do not normally establish in storage. See Appendix A for a list.

Contact the elevator management to indicate when an inspection will be carried out.

While at the facility, contact the manager of the facility to discuss any areas of concern and safety issues. If doing a follow-up inspection, this is an opportunity to have the manager attest that the previously recommended corrective actions have been taken. For safety, ask the manager if any hazardous actions (e.g., treatments, blow down cleaning) has recently been carried out at the facility. Avoid hazards by wearing the proper equipment or by postponing the inspection. Determine where, when and what product was used and the withdrawal period prior to entering the facility. This will help to assess if it is safe to inspect the facility. Finally, request to be accompanied by a staff member during the inspection.

4.2.1 Frequencies for Facilities at Standard Conformance Levels

Use the frequencies in the following table to inspect facilities that have obtained a standard level (i.e., AAA, AA, A or B) at their most recent inspection. The table has three columns; "Elevator Area" which lists where the facility(ies) that are being inspected are located , "Number of Inspections per Year" which suggest the number of inspections to target in each area , and "Recommended Inspection Frequency" which discusses what the frequency of inspections should be for the area listed.

Elevator Area:

Number of Inspections per Year:

Recommended Inspection Frequency:

Churchill

3, more or less depending on conformance levels, spread throughout the shipping season (i.e., from July to October).
Table note 1

The initial inspection should be conducted within the first 2 weeks that the elevator is open for the season and approximately every 6 weeks following that.

British Columbia

8, more or less depending on conformance levels, spread throughout the year.
Table note 1

Approximately one inspection every 6 weeks.

Other locations within Canada

6 to 8 per year, depending on conformance levels and length of operating season.Table note 1

The initial inspection should be conducted within the first 2-3 weeks that the elevator is open for the season. Inspections should occur approximately every 6 weeks following that. For elevators open all year round inspections should occur every 6 weeks.

Table Notes

Table Note 1

More inspections will be required if follow-up inspections are necessary. These follow-up inspections are necessary when CGC or CFIA inspectors need to verify on site that corrective actions have been taken. However, where a facility obtains consecutively two high conformance levels (i.e., AAA or AA), the next planned regular inspection will be skipped, with a maximum of two planned inspections skipped per year. For example, here are the conformance levels obtained by inspection (as indicated by the week the inspection took place) for a year and the skipped regular inspections (in brackets): 1st (AA), 7th (AA), 14th (skipped), 20th (AAA), 26th (AA), 33rd (AAA), 40th (skipped), and 46th (AA). In this example, only 6 regular inspections are necessary, not 8.

4.2.2 Frequencies for Facilities at Sub-Standard Conformance Levels

Partial or full follow-up inspections (FUI) are required for facilities that have obtained a sub-standard conformance level (i.e., "C" or "F") at their most recent inspection. See Section 4.4.3 for a description of conformance levels and Section 4.4.4. for information on FUI. The chart in Appendix B will assist an inspector in determining when and what type of FUI is required. The CFIA will not issue Phytosanitary Certificates until a standard conformance level has been met (in some cases this means an "A" rating or better). Once facilities have obtained the required conformance level, use the inspection frequencies specified in Section 4.2.1.

4.3 Inspecting Facilities

Using the equipment specified in Section 4.3.1, inspectors shall inspect facilities on site. Inspections shall be done by collecting samples in and assigning sanitation ratings to various locations, as applicable.

Samples shall include collecting visible insects or other pests, residues, and products stored in bins. If identification of visible pests can be done on site, simply take written notes (i.e., species and location) of their presence. If not, insects and other pests should be identified back at the office or sent to an entomologist for identification.

Rate sanitation as each floor, area or section of the facility is inspected, as specified in Section 4.4.1. The sanitation rating should be done at the time of inspection and not done later, after analysis of collected samples. No sanitation or infestation ratings shall be given to the interior of storage bins.

Inspectors should work with the elevator management to ensure that the facility is divided into logical inspection areas that are easily identifiable and of an appropriate size given the layout of the facility. Too large an area will reduce the impact of multiple sanitation problems or insect finds and create problems for a facility to contain or control a problem identified on the report. The CFIA or CGC inspector has the final authority in determining the appropriate areas for rating the facility. Should significant changes be proposed to the number and layout of the areas that are rated within a facility, the National Manager of the Grains and Field Crops section must provide prior approval before any changes can be made.

While inspecting a facility, it is recommended that inspectors start at the top of the facility and work down to its basement. The list below outlines some of the key areas to inspect;

In addition, at least 15% of the bins in the facility should be sampled per inspection, with the objective of ensuring that each bin of the facility is sampled at least once a year. Insect finds during bin inspections are not included in calculating the Total Points Lost for Infestation (TPLI).

4.3.1 Safety precautions:

Inspectors shall take all reasonable and necessary precautions to ensure the safety and health of all persons likely to be affected by their acts or omissions. This includes the following:

Avoid hazardous contact with moving machinery or fumigated products;

Obtain certification that fumigated products are safe to handle before sampling them;

Do not use open-flame or spark-producing equipment in the facility (i.e. cell phone, camera, lighter, etc.);

Flash lights must be spark resistant/explosion proof and CSA approved;

Never cross over or under belt conveyors, except where safe passageways are provided;

Be aware of emergency shut off devices for conveyors;

Never use benches, chairs, boxes or other makeshift stools in place of ladders;

Do not block walkways, stairways and exits with inspection equipment and samples; and

Stop the inspection if feeling dizzy, sick, weak, or if injured.

Inspectors should be aware of the facilities safety policies and procedures. Inspectors shall cooperate with any person exercising a duty imposed by the Canadian Occupational Safety and Health Regulations (COSH) in the facility. In case of emergency evacuation, follow the facility's procedures which should be posted on the premises as required by the COSH, Section 17.6(2). These procedures should include a plan of the building and the emergency evacuation plans. If possible, become familiar with the signals (i.e. horn) used in a fire emergency.

After an inspection, inspectors shall advise the manager that the inspection is completed. Inspectors shall report to their employer, and the manager of the facility, anything of circumstance that is likely to be hazardous to the safety or health of a person in the facility. Inspectors shall also report, in the manner prescribed by their employer, every accident or other occurrence arising in the course of or in connection with their inspection that has caused injury to a person in the facility.

A fully-operating facility is a hazardous environment to work in, and the risk level increases with advanced automation and reduction of staff in the plant. Equipment can start with little or no warning and place an inspector in a dangerous position. Awareness of the dangers is the best preventive measure against accidents and injuries. Therefore, as required by the Canada Labour Code and the COSH, and as an employer of inspectors, the CFIA has herein prescribed certain safety procedures. As employees, inspectors are responsible, pursuant to the Canada Labour Code, Part II, Section 126, to follow the above procedures. Note that grain handling facilities licensed by the CGC, certain feed mills, certain feed warehouses, flour mills and grain seed cleaning plants are under federal jurisdiction in safety matters.

4.3.2 Equipment Required

While inspecting facilities, inspectors shall carry or wear the equipment listed below. Note that inspectors shall ensure that their equipment is in good repair (functional and clean) and safe to use (i.e., ensure that they will not restrict movement and are not likely to get caught in moving machinery). Inspectors shall remove, cover or secure dangling accessories. Inspectors with long hair shall also tie it up.

Inspectors shall carry:

A powerful portable light (e.g., a cell flashlight, a six volt lantern, or a rechargeable miner's lamp). Portable lights must be explosion proof and have been approved by the Canadian Standards Association (CSA) for "Class II, Division 1 and Group G" locations, as per Rule 18-004 of the Canadian Electrical Code (CEC, 2.16), and should be marked as CSA approved. [As per Rules 18-008 and 18-058 of the CEC, "Class II, Division 1, Group G" locations include the working areas of grain handling and storage plants (e.g., rooms containing grinders, cleaners, graders, open conveyors or spouts, open bins or hoppers, mixers, automatic hopper scales, packing machinery, elevator heads and boots, dust collectors and all similar dust-producing machinery and equipment in grain processing plants, starch plants, sugar pulverizing plants, malting plants, hay grinding plants, and other occupancies of similar nature), which comprise atmospheres containing flour, starch, grain dust and other dusts of similarly hazardous characteristics. The use of such equipment is required as per the COSH, Part XVII, Paragraph 17.11.1.a, and Part VIII, Paragraph 8.3.2.]

Sampling equipment

A pencil and note pad for records.

Inspectors shall wear:

A CSA approved hard hat, in good condition, to protect from falling objects or unseen projections. [Protective head wear shall meet the CSA Standard Z94.1-M1977 as per Part XII, Paragraph 12.4, of the COSH.]

Properly fitted clothes that will not restrict movement or catch in moving machinery [as per Part XII, Paragraph 12.12, of the COSH]

Gloves to protect hands from sharp objects, cold, dirt, etc.

CSA approved safety shoes or boots with oil resistant cork or rubber soles and steel toes. [Protective footwear shall meet the CSA Standard Z195-M1984, as per Part XII, Paragraph 12.5.1, of the COSH.]

High visibility vests or coveralls, where required,[as per Part XII, Paragraph 12.13.a, of the COSH]

Hearing protection such as ear muffs or plugs, where required by warning signs or by facility management. [Hearing protection shall meet the requirements set out in CSA Standard Z94.2-M1984, Hearing Protectors, as per Part VII, Paragraph 7.7.3 of the COSH.]

Inspectors may wish to use gas detection devices to check locations where fumigation has taken place, or in areas where toxic gases could accumulate (e.g., pits, bins and other confined spaces).

4.4 Determining Ratings and Conformance Levels

Determine the sanitation and infestation ratings as specified in Sections 4.4.1 and 4.4.2, and determine the conformance level as specified in Section 4.4.3. The rating system herein is based on several years of experience in inspecting facilities that store and export grains and field crops. This experience has shown that when CFIA's standards are met, facilities and products exported from them have higher levels of freedom from pests.

4.4.1 Sanitation Rating

a. The following table is used for rating the sanitation of facilities. Its columns include "Rating" which is the overall numerical sanitation rating, "Quality and type of Residue" which provides the inspector with a description of a potential residue to base their observations on, "Residue Location" which provides the potential frequency that the residue can be observed in an area, and "Cleaning" which describes the frequency that the facility is sanitized. The inspector is to visually observe and rate each area in the facility, using the table:

Rating

Quantity and type of Residue

Residue Location

Cleaning

Excellent (4.0).

No residues or only a negligible film of fresh dust. There are no old residuesTable note 2 or crusted dust/grain.

Nowhere or only in a few areas.

Regular and thorough.

Good (3.0-3.9).

More than a film of dust and only minor accumulations of spilt grain, but there are no old residues Table note 2 or crusted dust/grain.

In a few areas, but limited on equipment or pipes.

Regular but cleaning is needed for a few areas.

Fair (2.0-2.9).

More than a film of dust and minor to moderate amounts of spilt grain, but with only minor accumulations of old residuesTable note 2 or crusted dust/grain.

In a few areas, which may include beams, equipment or pipes.

Irregular and is needed in several areas.

Critical (1.0-1.9).

More than a film of dust, and moderate to substantial amounts of spilt grain and moderate accumulations of old residuesTable note 2
or crusted dust/grain.

In several areas (but not everywhere), including beams, equipment or pipes. Old residues in a few areas.

Irregular and is needed for many areas.

Unacceptable (0.0-0.9).

More than a film of dust and substantial amounts of spilt grain and old residuesTable note 2 or crusted dust/grain. There also may be webbing material (i.e. insect webs).

Almost everywhere, including on beams, equipment or pipes. Old residues in several areas.

Irregular, has not been carried out for an extended period of time, and is needed for most areas.

Table Notes

Table Note 2

Residues are old if crusted, sprouted, clumped or discolored grain are observed, indicating that the residues have been there for an extended period of time. The status of the residues may be determined by questioning the facility employees and/or operator. Inspectors may immediately recommend corrective actions for conditions observed as specified in Section 4.5.

Table Notes

4.4.2 Infestation Rating

a. Visually observe each area for the presence of insects and take samples of residues found in the areas (For bin samples see Section 4.3). Inspectors may immediately recommend corrective actions for conditions observed on site. Where CGC inspectors are inspecting on behalf of the CFIA, they should immediately notify the CFIA headquarters when pests of quarantine significance to Canada have been found.

b. Compile the total insect finds (primary and secondary only) per type of insect and per location. Note that the finds in bin samples will not be included in the calculation of the infestation rating. Keep the compilation of all finds for the inspection report where corrective actions (as determined in Section 4.5) will be recommended.

c. Determine the number of points lost for infestation (PLI) per location in the facility and type of insect (primary vs secondary) using the compilations (excluding the finds in bins) done in Section 4.4.2b and using the table below.

d. Should primary and secondary insects be found in the same area, only the find that results in the greatest points lost will be included in the report. For example, one primary insect and two secondary insects are found under a cleaner on the Cleaner Floor. For this floor, the number of points lost for infestation would be 5 as the primary insect is more serious and results in a greater number of points lost.

e. Should several insects be found throughout an area that is to be rated, the points lost should only reflect the most serious find. For example the Cleaner Floor is rated as all one area and secondary insects are found in several places (i.e. along the walls, around beams, and under the cleaners). For this area, the number of points lost for infestation on the report for secondary insects is 2. Evidence of the presence of insects, but where no live insects are found (e.g. trail of larva or adult of Tenebrio molitor in dust) does not result in points lost.

When the number of insects (primary and secondary only)Table note 4 are found in the specific area within the facility (excluding bins) the points lost are as outlined in the table below:

Insect detections

Primary insects:

Secondary insects:

None.

0

0

Insects in one place within an area and far from structuresTable note 4 or conveyances that grain may move through (e.g., in a corner or along a wall on the motor floor).

1

0

Insects in several places within an area and far from structuresTable note 4 or conveyances that may move or store grain (e.g., in different corners and along the wall of the motor floor).

2

1

Insects in one or several places within an area and near to structuresTable note 4 or conveyances that may move or store grain (e.g., under cleaners or belts, spillage near to bin tops)

5

2

Insects in one or several places within an area and in structuresTable note 4 or conveyances may move or store grain (e.g., in a cleaner or on the belt).

10

5

Table Notes

Table Note 4

The number of insects shall be determined as specified in Section 4.4.2. "Structures that usually are in contact with products to be exported or stored" include conveyor belts, scales, cleaners, dumper pits, legs, shipping galleries, etc.

4.4.3 Conformance Levels

To determine the conformance level that a facility obtains, add the total points lost for sanitation (TPLS)Table note 6 and the total points lost for infestation (TPLI)Table note 7, and use the following table:

TPLS + TPLI =

Conformance Level

Elevator Rating

0 - 2

AAA: Facilities that meet this level have shown a superior performance. The conditions observed during the inspection exceed the CFIA requirements for sanitation and infestation.

Standard

3 - 6

AA: Facilities that meet this level have a good phytosanitary performance. The conditions observed during the inspection meet the CFIA requirements but some problems may have been identified.

Standard

7 - 11

A: Facilities that meet this level have an adequate phytosanitary performance. The conditions observed during the inspection meet the CFIA requirements but problems, which place the facility at a lower acceptability limit in meeting the requirements of the CFIA, have been identified.

Standard

12 - 17

B: Facilities that meet this level are at the lowest limit for phytosanitary performance and should be showing evidence that they are working on improving the condition of their facility. There are obvious deficiencies, as outlined in an Advisory Notice issued to the management of the facility, which require prompt corrective actions. A continuous "B" rating is not acceptable.

Standard

18 and above.

C: Facilities that meet this level are in a critical phytosanitary situation. The conditions observed during the inspection place the facility below an acceptable level and do not meet the requirements of the CFIA. There are critical deficiencies, as outlined in a Letter of Warning issued to the management of the facility, which require immediate corrective actions.

Sub-Standard

18 and above.

F: Facilities at this level are failing to meet the CFIA phytosanitary requirements over a specific period of time. The conditions observed during the inspection indicate that: a) the corrective actions, as outlined in the inspection report and its Letter of Warning sent for the previously obtained "C" or "F" level, have not been taken; and b) the facility still does not meet an acceptable Standard rating of "A" or better.

Sub-Standard

4.4.4 Follow-up Inspections - General

A follow-up inspection (FAO) occurs when a facility must be inspected shortly after the last inspection to ensure that all corrective actions have been taken. The procedures for conducting a FUI are the same as regular inspections. A followup inspection may be arranged at the discretion of the inspector on the basis of elements including rating history of the facility, frequency of regular facility inspections in region, severity of non-compliances, as well as other factors

There can be two types of FUI:

Partial FUI - In this case inspectors are returning to inspect only the areas that were outlined as areas of concern on the previous report. However, inspectors should not ignore new problem areas if noticed.

Full FUI- In this case inspectors are returning to do a complete facility followup inspection to ensure that the entire facility, not just the areas of concern are in satisfactory condition and that no new problems exist.

In most cases the FUI should occur approximately 10 business days after the last inspection or sooner if requested by the management of the facility.

Following up on a "B" rating; If necessary, inspectors shall conduct a partial FUI to verify that corrective actions recommended from the previous inspection have been taken or were completed properly.

Following up on a "C" or "F" rating; Followup inspections are mandatory in all cases.

When doing follow-up inspections, carry the previous inspection report along with the current inspection report and present these to the manager or operator of the facility to attest that the previously recommended actions have or have not been taken.

a. "B" Rated Facility Receives a "B" Rating on the Next Regular Inspection.

A facility which receive a "B" rating on a regular inspection, and then receives a "B" rating on the next regular inspection, will be subject to a partial FUI. If the FUI report indicates a "B" or "C" rating, the conformance level of the facility shall be considered sub-standard ("C"). The issuance of Phytosanitary Certificates will be considered on a case by case basis until the next inspection is completed. The facility must provide an action plan detailing how they intend to deal with the problem(s) within 5 days.

If the facility does not comply within 10 days or upon completion of the FUI should the inspection report indicate a "B" or "C" rating, the facility shall be given an "F" rating.

A facility which receives a "C" rating on a Regular Inspection requires a partial FUI. Should the facility receive a "B" rating on the partial FUI, a second partial FUI is required.

Should the second partial FUI result in an inspection report rating of a "B" or lower, the facility shall be given a "C" rating. Phytosanitary Certificates will be issued for products exported from that facility on a case by case basis until the next inspection is completed. The facility must provide an action plan detailing how they intend to deal with the problem(s) within 5 days. A further partial FUI should be scheduled.

If the facility does not comply within 10 days or upon completion of the further FUI should the inspection report indicate a "B" or "C" rating, the facility shall be given an "F" rating.

A facility which receives a "C" rating on a regular inspection requires a partial FUI. Should the facility receive a "C" rating on the partial FUI, the facility shall be given an "F" rating.

d. Facility receives an "F" rating

In this case, Phytosanitary Certificates will not be issued for any products exported from that facility until the facility is re-inspected and receives a standard rating ("A" or better) on a full FUI.

A full FUI of the facility should occur following a request by the management of the facility or within 10 working days, whichever comes first. This inspection will also involve CFIA inspection staff where inspections are normally performed by the CGC. The CFIA inspector should then contact their local program officer to notify the Grains and Oilseeds Section, Plant Health and Biosecurity Division to inform them of the pending issue.

Should the full FUI result in a report rating of a "B" or "C" the facility shall remain sub-standard ("F"). A meeting should be held with the management of the facility and involve both CGC and CFIA staff, where applicable, to review the issues that continue to cause the facility to receive a sub-standard rating and the corrective actions required. In these situations, the inspection report should be completed by the CGC staff, where applicable, and forwarded to the CFIA inspector so that a Prohibition of Movement (PofM) warning letter can be sent along with the report. This letter should be signed by a CFIA Area Program Network Specialist. At this time CFIA will take the lead in coordinating any further inspections and correspondence with the facility. A further full FUI should be arranged.

Should the inspection results of this further full FUI indicate that the facility is still at a "B" rating or lower a Prohibition of Movement should be issued to the facility along with a letter explaining the impact of the prohibition and the full FUI inspection report. At this point the facility will no longer be able to move any product out of the facility without a CFIA issued Movement Certificate.

Inspectors should only return to the facility upon a request from the facility's management which indicates that all corrective actions have been taken and they are ready for re-inspection.

4.5 Corrective Actions

Determine which corrective actions to recommend, using the information herein. Inspectors may recommend actions verbally as they inspect the facility but shall always reflect these recommendations in writing in the inspection report. Reports shall be done as specified in Section 4.6.2.

The facility's pest control officer should only use products registered by the Pest Management Regulatory Agency (PMRA) and recommended for the intended use. Inspectors do not have the responsibility to recommend particular pest control products. The facility's pest control officer is responsible for performing treatments as authorized under the Pest Control Products Act, which is administered by the PMRA.

Inspectors are responsible for verifying that the bins recommended for treatment have been effectively treated by analyzing a sample taken from each treated bin. These post-treatment samples shall not contain any live insects. If they do, re-treating the bin will be required. Inspectors shall only take such samples after obtaining authorization from the facility's pest control officer that the products to be sampled are free from hazardous substances and safe to handle.

4.5.1 Empty Bins Infested with Primary or Secondary Insects

If live insects are found, recommend the cleaning of the interior of the bin, and the cleaning of the interior and exterior of the valves. Also recommend the spraying of the valves (interior and exterior).

4.5.2 Bins Infested with Insects of Quarantine Significance to Canada

If live quarantine insects are found, recommend the fumigation of the entire content of the bin. For a list of insects of quarantine concern to Canada, see Appendix A. Samples of any possible quarantine insects must be forwarded to CFIA as soon as possible. Where CGC inspectors are inspecting on behalf of the CFIA, they should immediately notify the CFIA headquarters when pests of quarantine significance to Canada have been found.

4.5.3 Bins Storing Products Infested with Primary Insects

a. If live insectsTable note 8 are found in a bin drop sample, recommend that the bin be treated. The facility's pest control officer should notify the inspector of the treatment to be used and the anticipated date of when the treatment will be completed and samples can be obtained.

b. This bin should be sampled following the completion of the treatment, as indicated by the facility's pest control officer. Notification should be provide to the facility upon completion of the sample analysis. Should live insects be detected the facility will be required to retreat the contents of the bin.

If Lepidoptera adults are found see Section 4.5.5. For other secondary insects, do as specified herein:

If mites or Lepidoptera larvae are found in the grain in the bin then at least 30% of the grain should be turned (i.e. moved out of the bin and re-circulated back into the bin)

If Coleoptera are found, recommend treating of the valve area immediately and then check, clean and treat the bin once it has been emptied. Notification should be provided to the facility upon completion of any sample analysis. Should live insects be detected the facility may be required to treat the entire contents of the bin.

If live secondary Lepidoptera adults are found, most likely around the valves, do as specified herein:

Recommend the cleaning and spraying of the interior and exterior of the valves of the bin and that at least 30 % of the grain in the bin be turned (re-circulated). The bin should then be checked, cleaned and treated once it has been emptied.

4.5.6 Other Organisms in Areas other than Inside Bins

The following table identifies other organisms in areas other than inside bins. The table lists the potential organisms in the "Observation" column, and how they could be addressed in the adjacent "Recommendation" column.

Observation

Recommendation

Birds, rats or mice and their droppings, and insects that are not primary or secondary insects (e.g., flies).

These pests are not of quarantine concern. However, there presence suggests that sanitation is not adequate, and inspectors may suggest: a) screening to prevent access to birds, mammals, and insects; b) rodent traps; and c) cleaning.

Insects that cannot be identified locally.

Corrective actions based upon the identification information provided by either the Centre for Plant Quarantine Pests (CPQP) within CFIA or the Chief Entomologist with the CGC.

4.5.7 Residues in Areas other than Inside Bins

The following table identifies residues in areas other than inside bins. The table lists the potential residues in the "Observation" column, and how they could be addressed in the adjacent "Recommendation" column.

Observation

Recommendation

A non-existent or negligible film of fresh dust in a few areas. There are no old residues or crusted dust.

The continuation of the cleaning regime.

More than a film of fresh residues, including or not the beams, equipment or pipes, and in a few or several areas. There are no old residues or crusted dust/grain.

The cleaning of these areas.

Treatment with an approved pesticide may be required.

More than a film of fresh and old residues, including webbing material (i.e., spider or insect webs), in several areas or everywhere, including the beams, equipment or pipes.

The immediate cleaning of all the areas of the location, including beams, equipment and pipes. This recommendation shall be done on site (verbally and, subsequently, in writing).

Treatment with an approved pesticide is required.

4.6 Analyzing Data and Reporting Results

4.6.1 Analysis

In the laboratory, detect and identify small organisms found in the facility or in samples.

Compile the detection results by location in the facility (i.e., by floor, boot, leg, bin, etc., including area description such as a bin number).

Determine the average sanitation rating (ASR) as specified in Section 4.4.1c.

Determine the total points lost for sanitation (TPLS) and infestation (TPLI) as specified in Sections 4.4.1d. and 4.4.2f

4.6.2 Report

Only trained inspectors shall write inspection reports. These reports shall accurately, clearly and unambiguously convey the results of the inspection, reflecting the sanitation and infestation conditions in the facility at the time of inspection.

Including the correct report number on each report is key to tracking and filing all elevator inspection reports. The report number should be made up of the area (West, Thunder Bay, Bayport, East) where the facility is located; the facility name (or representative acronym chosen by the local inspection office); the current calendar year; and the sequential number of the report. (For example, the third report of 2005 for MEGA in Thunder Bay would be numbered as Thunder Bay-MEGA-2005-3). For follow-up reports see Section 4.6.3

Corrections or additions to an inspection report after issuance shall be made only by a further document suitably marked "Supplement to Inspection Report # ...".

When updates are made to the Inspection Report Template the new version will be circulated by CFIA program staff through the CFIA area specialists and the CGC program lead.

The report shall be done using legal size paper and bear the CFIA and CGC logo in header at the top of the page, and have bilingual headings.

4.6.3 Follow-up Inspection Report

An inspection report shall be completed when a FUI occurs (either for a partial or full FUI). When conducting a FUI the report shall be completed by amending the previous inspection report and report number. The FUI report shall include the results of the on-site follow-up inspection to verify that corrective actions recommended from the previous inspection report have been completed and are effective, as well as any additional areas which were inspected as part of the follow-up inspection.

The FUI report shall be issued as follows:

Following the existing Report No. add the statement "FUI [insert FUINo., i.e. "1" for the first FUI, "2" for the second FUI, etc.]" (For example, the third inspection at MEGA resulted in a "C" rating. Therefore, a follow-up inspection is conducted. The report would be numbered as follows, Thunder Bay-MEGA-2005-3-FUI-1)

Change "The Date of Inspection" to the date of the FUI.

Highlight those areas in the report which have been amended to include information from the FUI (e.g. using a bold font, or a foot note).

Amend the Points Lost for Infestation and Sanitation Rating for those locations which have been included in the FUI.

Re-calculate the Average Sanitation Rating (ASR) using the amended ratings determined from the FUI. In the case of a partial FUI, use the amended ratings from the locations included in the partial FUI and the ratings from the previous inspection report for those locations not included in the follow-up inspection to determine the new ASR.

Re-calculate the total points lost for sanitation (TPLS) and infestation (TPLI) and the new conformance level using the points lost from the locations included in the FUI. In the case of a partial FUI, use the points lost from the previous inspection report for those locations not included in the follow-up inspection. For a full FUI all areas and ratings should be re-assessed.

Include the following statement, in the "Remarks" Section of the Inspection report, "This is a [partial or full] follow-up inspection to verify corrective actions identified in the original inspection report. The original inspection was conducted on [insert dates of the regular inspection]"

Amend the "Details and Recommended Corrective Actions to Upgrade the Conditions of the Premises" Section to identify those corrective actions recommended as a result of the follow-up inspection in a separate section. This shall be reported first in this section under a sub-heading titled "Details and Recommended Corrective Actions from Follow-up Inspection." The problem areas and corrective actions recommended on the previous Inspection Report shall be retained in this section under a sub-heading titled "Details and Recommended Corrective Actions from Previous Inspection." This shall be done to include those problem areas and recommended corrective actions from areas which were not re-inspected as part of a partial FUI.

4.6.4 Examples of Letters

The example letters listed below should be attached to any inspection reports that obtains a "B" rating or lower. Should any changes to one of these template letters be required the inspector should contact their Area Grains and Oilseeds Program Officer prior to changing the letter. Any letters that make reference to an issuance of a Prohibition of Movement are to be issued by a CFIA Area Grains and Oilseeds Program Officer.

For facilities which receive a B rating, inspectors shall add an Advisory Notice (FUI planned, Appendix B and FUI not planned Appendix C) to the inspection report. This notice shall be signed by the CGC Regional Director (or designate), if a CGC inspector wrote the report. The notice shall be signed by the CFIA inspector if a CFIA inspector wrote the report. This notice is to advise the manager of the facility that the facility is at the lower level of acceptability for phytosanitary performance, and that there are deficiencies which require prompt corrective action.

For facilities at sub-standard conformance levels, inspectors shall add a Warning Letter (Appendix D) to the inspection report. This letter shall be signed by the CGC Regional Director (or designate), if a CGC inspector wrote the report. The letter shall be signed by the CFIA inspector if a CFIA inspector wrote the report. This letter is to provide the manager of the facility with a concise notice that the facility has obtained a sub-standard conformance level. For sub-standard facilities, the inspection report package shall be distributed by fax or e-mail on the same day as the inspection or as soon as available.

4.7 Distributing and Filing Records

Inspectors shall record their inspections by producing and/or collecting samples, labels of samples or documents that serve to identify samples (e.g., tickets), laboratory results, inspection reports, and any other relevant information. Inspectors shall distribute and file these records as specified in Sections 4.7.1 and 4.7.2.

4.7.1 Files

File, or keep in a manner which allows traceability, temporary records (e.g., labels or loose notes containing laboratory results, ratings, finds, etc.) until they are transferred to an inspection report or final document.

File the records of any deviations, additions to or exclusions from the requirements and procedures of this PI-001 when it is necessary to use methods and procedures which are not as required.

File all final documents, e.g., reports.

Keep files up-to-date and available to auditors or other concerned CFIA and CGC personnel. Keep all final documents for five years.

4.7.2 Distribution

Final documents and other relevant information shall be distributed electronically as specified below. For sub-standard (i.e. "C" or "F") facilities, distribution shall be done electronically as soon as possible. Notify all relevant parties of significant changes to documents immediately, or as soon as possible.

Original report

Facility of General Manager

Carbon copy of the report

CFIA local inspection office and/or inspector

CFIA national headquarters (i.e. Grains and Oilseeds Section)

CGC National Headquarters (i.e. Grain Sanitation and Infestation Control Coordinator), for inspections done by CGC inspectors

Area specialist (CFIA conducted inspections)

File inspection report at local office (CFIA)

Ensure that records are maintained in a secure manner to protect proprietary rights and confidential information. The distribution of confidential information with staff shall be limited to those persons whose job requires that they have such information.

4.8 Concurrent Inspections

It is recommended that Canadian Food Inspection Agency (CFIA) inspectors conduct concurrent inspections of grain terminal and transfer elevators where the inspections are performed by Canadian Grain Commission (CGC) inspectors.

4.8.1 Purpose

The purpose of the inspection is:

to provide inspection reports which confirm that the CFIA and CGC inspector concur with the inspection findings and any corrective actions identified as a result of the inspection, and that the inspections and reporting are conducted in a manner consistent with the inspection procedures.

to provide an opportunity for CFIA inspectors to remain familiar with the logistics of the grain handling facilities in their area and with the CGC inspection staff that inspect them on behalf of the program.

to exchange information between CFIA and CGC inspectors on techniques, systems, equipment and changes that may occur within the program.

4.8.2 Scope

These guidelines apply to all individuals performing terminal or transfer elevator inspections, those who oversee them and those who develop and monitor the programs that affect these inspections.

4.8.3 Definition

A concurrent elevator inspection is an inspection activity whereby a CFIA inspector requests to participate in the elevator inspection process with a CGC inspector. Participation includes sampling, rating and discussing the phytosanitary condition of the facility throughout the inspection process to ensure that both inspectors are evaluating the specific elevator in a similar manner.

4.8.4 Frequency

Concurrent elevator inspections should be conducted twice per year with each individual who is considered by the CFIA to be responsible for conducting, reporting on and following up on elevator inspections. Concurrent inspections should occur at different facilities on a rotational basis. Should more than one CGC inspector be present during an elevator inspection, the concurrent inspection will only be considered to be with one of the inspectors.

4.8.5 Procedure

The CFIA inspector will contact the specific CGC inspector and request to participate in a concurrent inspection at least 5 working days prior to the intended inspection date.

Both inspectors will participate in the inspection, including the collection of samples (as directed by the lead inspector) and the rating of the areas inspected.

Ongoing discussion regarding the inspection, the findings and ratings of each area or floor is encouraged throughout the entire inspection.

A post inspection meeting should take place just following the concurrent inspection to review the samples taken and discuss the information that will be included within the official report. If this cannot occur immediately after the inspection, a meeting will occur within 48 hours of the completion of the inspection.

A meeting may also be required within 48 hours to review the results of the samples taken during the inspection and further discuss the final report should sample results be significantly different.

The CGC inspector has the final responsibility for completing the official report of the inspection and should file this report within 48 hours of the inspection or post inspection meeting.

4.8.6 Discrepancies

Should differences of opinion between inspectors exist, that cannot be resolved through discussions during or immediately following the inspection, then further discussion between the CFIA and CGC inspectors should be continued at a site remote from the elevator being inspected.

Discrepancies that cannot be resolved should be forwarded to the respective program managers or specialists for follow up. The program managers or specialists have the authority to request a follow-up concurrent inspection to rectify discrepancies if required.

4.9 Filing and Distribution

Reports to be kept for 5 years as per CFIA policy.

Reports will be distributed to as per distribution list outlined in Section 4.7.2 of PI-001.

Appendix A - Various Insects by Type (Primary or Secondary)

The insects listed herein do not all occur in Canada. This list is not exhaustive.

In this list, unidentifiable larvae of moths (Lepidoptera) shall be considered as secondary insects.

The CFIA considers Cryptolestes turcicus and C. pusillus as primary insects, although some references consider them as secondary insects, they are not easily distinguishable from the very serious insect C. ferrugineus.

Primary Stored Product Pests

The following is a table listing different primary pests that may be found in stored products.

Table Notes

Table Note 1

Table Note 10

These Lepidoptera insects are considered by some references as primary insects as they can establish and reproduce on whole sound grain if appropriate conditions exist for an extended period of time. For elevator inspection purposes these insects are considered to be secondary pests due to their biology and the methods used to control them. However, should these insects be present immediate control actions should be taken to mitigate against further population increases.

Appendix B - Advisory Notice (FUI planned) Template

[Include address of sender.] [Include date.] [Include name and address of the person in charge of the facility.]

Dear [include name of the receiver]

This letter is to advise you that [include name of the facility] has been inspected and obtained a "B" rating. While the facility will continue to be considered at a standard level, it is presently at the lowest limit for phytosanitary performance. See the attached inspection report [include number of the report] for details on the inspection. The inspection was conducted on [include date(s) of inspection]. There are deficiencies which require prompt corrective action. Failure to complete these corrective actions places the facility at risk of receiving a sub-standard (ie., a "C" rating) on subsequent inspections and further action may be taken.

Please review the Details and Recommended Corrective Actions page of the attached inspection report for a complete list of the problem areas.

Please contact our local office at (include telephone and facsimile number) when the problem area(s) has (have) been corrected. A follow-up inspection will be conducted on (include date, it should be within 10 of the day of the last inspection) or earlier if requested to ensure that serious deficiencies identified in the report have been rectified.

Thank you for your prompt attention to this matter.

Sincerely, [Include signature of the signatory.]

[Print name of the signatory.] [Include position title of the signatory.]cc. [Include distribution list, as specified in Section 4.7.2.]

Appendix C - Advisory Notice (FUI not planned) Template

[Include address of sender.] [Include date.] [Include name and address of the person in charge of the facility.]

Dear [include name of the receiver]:

This letter is to advise you that [include name of the facility] has been inspected and obtained a "B" rating. While the facility will continue to be considered at a standard conformance level, the rating is at the lowest limit for phytosanitary performance. See the attached inspection report [include number of the report] for details on the inspection. The inspection was conducted on [include date(s) of inspection]. There are deficiencies which require prompt corrective action. Failure to complete these corrective actions places the facility at risk of receiving a sub-standard (ie., a "C" rating) on subsequent inspections and further action may be taken.

Please review the Details and Recommended Corrective Actions page of the attached inspection report for a complete list of the problem areas.

Thank you for your prompt attention to this matter.

Sincerely, [Include signature of the signatory.]

[Print name of the signatory.] [Include position title of the signatory.]cc. [Include distribution list, as specified in Section 4.7.2.]

Appendix D - Warning Letter Template

[Include address of sender.] [Include date.] [Include name and address of the person in charge of the facility.]

Dear [include name of the receiver]:

This letter is to inform you that [include name of the facility] has been inspected and presently is at a sub-standard conformance level, ie., [include conformance level obtained, "C" or "F"]. See the attached inspection report [include number of the report] for details on the inspection. The inspection was conducted on [include date(s) of inspection]. A facility does not meet a standard level when major deficiencies are observed, placing the facility at a level that does not meet the Canadian phytosanitary standard.

[Include one of the following statements. [For facilities that have obtained a "C" level:] Based on CFIA policy, issuance of Phytosanitary Certificates will be considered on a case by case basis for a period of 10 business days following the date of the last inspection. A detailed action plan indicating all corrective action(s) to address the point(s) identified in the report must be received by our office within 5 days and subsequently verified by a follow-up inspection within 10 days following the date of the last inspection, or this facility will drop to an "F" level. At which time, Phytosanitary Certificates will not be issued for products exported from your facility unless, at the time of the followup inspection, the facility meets a phytosanitary standard of "A" or better.

[For facilities that have obtained an F level:] Based on CFIA policy, Phytosanitary Certificates will not be issued for products exported from your facility until the facility meets a phytosanitary standard of "A" or better. A full followup inspection of the entire facility will occur within 10 business days or following a request by your facility's management. If the results of this inspection are found to be less than an "A", your facility will be referred to Canadian Food Inspection Agency for appropriate action and CGC staff will not conduct any further inspections until advised by CFIA.

Please review the Details and Recommended Corrective Actions page of the attached inspection report for a complete list of the problem areas.

A follow-up inspection will be conducted on (include date, it should be within 10 of the day of the last inspection) or earlier if requested before.

Thank you for your prompt attention to this matter.

Sincerely, [Include signature of the signatory.]

[Print name of the signatory.] [Include position title of the signatory.]cc. [Include distribution list, as specified in Section 4.7.2.]